A) ABSTRACT / HEADNOTE

The Supreme Court in Buddu Satyanarayana and Others v. Konduru Venkatapayya and Others, [1953] SCR 1001, deliberated on a pivotal dispute involving temple property claimed to be alienated by archakas (temple priests). The case revolved around whether an inam grant dated 1770 A.D., relating to over 93 acres of land, was made to the temple itself or to its archakas burdened with the responsibility of religious service. The legal conflict also centered on whether the grant covered only melvaram rights (revenue rights) or the land in entirety. The appellants (archakas) claimed long possession of the land and invoked the doctrine of “lost grant,” seeking presumption of ownership through continued, peaceful enjoyment.

Rejecting these claims, the Supreme Court held that the grant was made directly to the temple and not to the archakas. The Court emphasized that where documentary evidence like the Inam Register and statements during the Inam Inquiry establish title, no presumption of a lost grant can arise. It was also established that the grant included both melvaram and kudivaram rights, confirming full ownership in favour of the temple. The Court decisively rejected the equitable pleas raised by archakas, especially in light of their adverse claim against the temple. This judgment remains a significant precedent regarding the evidentiary value of Inam documents and temple property law.

Keywords: Inam Grant, Melvaram Rights, Kudivaram Rights, Temple Property, Lost Grant Doctrine, Archakas, Hindu Religious Endowments

B) CASE DETAILS

i) Judgment Cause Title: Buddu Satyanarayana and Others v. Konduru Venkatapayya and Others
ii) Case Number: Civil Appeal No. 121 of 1951
iii) Judgment Date: 26 February 1953
iv) Court: Supreme Court of India
v) Quorum: Justice Mehr Chand Mahajan and Justice S.R. Das
vi) Author: Justice S.R. Das
vii) Citation: [1953] SCR 1001
viii) Legal Provisions Involved: Madras Hindu Religious Endowments Act, 1927, Inam Regulations
ix) Judgments Overruled by the Case: None
x) Case is Related to: Hindu Religious Endowments Law, Property Law, Civil Law

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

This civil appeal raised crucial questions surrounding temple land ownership and the proprietary rights of archakas. The roots of the dispute lie in an inam grant allegedly executed in 1770 A.D. by one Janganna Rao, the then Zamindar of Rachur. The issue arose when Konduru Venkatapayya, appointed as Executive Officer under the Madras Hindu Religious Endowments Act, 1927, initiated a suit seeking possession of lands occupied by archakas and their lessees.

The archakas, in return, denied the temple’s title, claiming ownership through long possession and asserting their hereditary role as priests. The High Court at Madras dismissed their appeal after the Subordinate Judge ruled in favour of the temple. The matter was escalated to the Supreme Court, where fundamental principles concerning possessory rights, the doctrine of lost grant, and classification of inam lands were critically analysed. The decision reflects an intersection of historical records, colonial-era land policy, religious endowment jurisprudence, and evidentiary rigour in temple litigation.

D) FACTS OF THE CASE

The property in question spans approximately 93 acres and 33 cents. It lies within the precincts of Sri Somasekharaswami Temple at Kotipalle, Donepudi. The temple was notified under the Madras Hindu Religious Endowments Act on 26 October 1939, and an Executive Officer was appointed on 15 July 1942. The plaintiff, Konduru Venkatapayya, acting in his official capacity, filed a suit in forma pauperis for recovery of the land from 43 defendants, comprising archakas (Defendants 1–16) and their tenants (Defendants 17–43).

The claim asserted that the land belonged to the temple and had been wrongfully usurped by the archakas, who had historically rendered religious services but had started to claim ownership adversely. A registered notice was issued demanding possession, but the defendants failed to comply. The Subordinate Judge ruled in favour of the temple, a decision upheld by the High Court. The appeal before the Supreme Court arose under leave granted by the High Court. The central issues were the nature of the inam grant and the legitimacy of the archakas’ adverse claim.

E) LEGAL ISSUES RAISED

i) Whether the inam grant was made in favour of the temple or to the archakas subject to service obligations?

ii) Whether the grant included ownership of the land (both melvaram and kudivaram) or only the melvaram rights?

F) PETITIONER / APPELLANT’S ARGUMENTS

i) The counsels for the Appellants submitted that:

The archakas and their forefathers had enjoyed undisturbed possession for over 150 years, which presumes a lawful origin. They relied on the doctrine of lost grant, citing long-standing peaceful enjoyment without challenge. The claim was that the grant must have been to the archakas, burdened with religious duties, and not to the temple per se. Furthermore, they argued the grant covered only melvaram rights. They cited an unreported Madras High Court decision in The Board of Commissioners for the Hindu Religious Endowments, Madras v. Parasaram Veeraraghavacharyulu to support the proposition that if assessment equals income, only revenue rights were granted.

The appellants emphasized that equity must be considered, asserting that even if ownership was with the temple, archakas deserved equitable protection given their historical service and reliance on the land for livelihood.

G) RESPONDENT’S ARGUMENTS

i) The counsels for the Respondents submitted that:

The documentary evidence, particularly Exhibit P/3 (Inam Register, 1860) and Exhibit D/3 (statement during Inam Inquiry), confirmed the temple as the grantee. The documents classified the grant as Devadayam, clearly for temple support. No reference was made to archakas as grantees. The Respondents argued that such explicit documentary evidence precluded any presumption under the lost grant doctrine, as laid down in Sundaram Ayyar v. The Sub-Collector of Ramnad (1902) ILR 25 Mad 149.

They stressed that the archakas never claimed ownership during the Inam settlement process and their assertion now was opportunistic and adverse to the deity. Hence, the suit for ejectment was legally sound and justified.

H) RELATED LEGAL PROVISIONS

i) Madras Hindu Religious Endowments Act, 1927 – Chapter VI-A, especially concerning management of temples and appointment of Executive Officers.
ii) Doctrine of Lost Grant – Presumption of legal origin from long possession, as considered in Raja Rajan v. Sundaram ILR 25 Mad 141.
iii) Property Law Principles – Differentiation between melvaram and kudivaram rights under Indian agrarian tenure systems.

I) JUDGEMENT

a. RATIO DECIDENDI

i) The Supreme Court held that when reliable documentary evidence exists, such as the Inam Register and Inam Inquiry statements, no presumption under the doctrine of lost grant can arise. The documents unequivocally recorded the temple as the grantee. The grant was classified as Devadayam, and the temple was noted as the Inamdar. Furthermore, the Court clarified that the inam included both melvaram and kudivaram rights based on income exceeding the tax assessment, distinguishing it from cases where income equaled assessment.

b. OBITER DICTA 

i) The Court noted that in proceedings for framing temple schemes, considerations of archakas’ welfare may apply. However, in a suit for ejectment based on title, such equitable pleas are irrelevant. The archakas had asserted adverse claims, undermining any moral equity they might otherwise have enjoyed.

c. GUIDELINES 

• Inam documents like Registers and Inquiry statements hold conclusive value in establishing grantee identity.

• The doctrine of lost grant cannot override express documentary evidence.

• When grant income substantially exceeds revenue assessment, it supports a presumption of complete ownership (melvaram + kudivaram).

• Equity does not favor those who assert adverse claims against religious endowments.

• Archakas are mere service-holders unless a valid transfer of ownership is proven.

J) CONCLUSION & COMMENTS

The decision in Buddu Satyanarayana v. Konduru Venkatapayya provides a doctrinal and practical reaffirmation of temple property jurisprudence. It lays down a strict evidentiary standard in property disputes involving Hindu religious institutions, giving primacy to colonial-era revenue documents. The rejection of equitable claims in the face of adverse assertions also acts as a deterrent to unauthorized occupation of temple lands. The Court’s disapproval of extending moral considerations in title suits ensures that religious endowments remain secure and protected from misappropriation. This ruling continues to guide temple property litigation, especially in South India.

K) REFERENCES

a. Important Cases Referred

i) Yelamanchili Venkatadri v. Vedantam Seshacharyulu, AIR 1948 Mad 72
ii) Raja Rajan v. Sundaram, ILR 25 Mad 141
iii) Sundaram Ayyar v. The Sub-Collector of Ramnad, ILR 25 Mad 149
iv) The Board of Commissioners for the Hindu Religious Endowments, Madras v. Parasaram Veeraraghavacharyulu (Unreported, Madras HC, Appeal No. 213 of 1942)

b. Important Statutes Referred

i) Madras Hindu Religious Endowments Act, 1927 – Chapter VI-A
ii) General principles of Inam Regulations under British-era land grants